This policy explains how SWARM Holdings Ltd, trading as SWARM AI Systems (“SWARM”, “we”), collects, uses and protects personal data. It describes our current practices under UK data-protection law; it is not a substitute for your own legal advice.
If anything is unclear, email stephen@swarmaisystems.com and we will answer in plain English.
SWARM Holdings Ltd is a private limited company registered in Scotland (Company No. SC884785), with its registered office in Paisley, Scotland, UK. We trade as “SWARM AI Systems”. The current registered-office record is available from Companies House.
Founder and Data Protection point of contact: Stephen Ward — stephen@swarmaisystems.com.
ICO Registration Number: ZC144402. Registered as a data controller under the Data Protection Act 2018.
| Category | Examples | How we get it |
|---|---|---|
| Contact data | Name, business name, email, phone, country | You give it to us — web form, email, call, or via your business’s public listing |
| Business and Diagnostic data | Business website, services, enquiry routes, supplied access, reported problems and the evidence used in a Diagnostic or Sprint | You provide it, or we observe it on the public business journey you ask us to assess |
| Payment data | Card details — processed by Stripe, never stored by us | You enter it on Stripe Checkout when you buy |
| Usage data | Pages visited, clicks, device type, anonymised IP | Your browser tells us via our hosting provider Vercel |
| Communications | Emails, WhatsApp messages, call transcripts and recordings | You send them; we may record calls for training and QA — we will tell you at the start of the call if we are recording |
We do not knowingly collect data from children under 16. If we learn we have, we delete it.
| Purpose | Legal basis (UK GDPR Art. 6) |
|---|---|
| To deliver a Business Diagnostic, Revenue Recovery Sprint or another product you have bought | Performance of a contract — Art. 6(1)(b) |
| To answer questions you send us | Legitimate interest in running our business — Art. 6(1)(f) |
| To respond to an enquiry or action you initiated through an owned SWARM channel | Legitimate interest in responding and taking steps you requested — Art. 6(1)(f) or Art. 6(1)(b) |
| To send optional marketing you requested | Consent — Art. 6(1)(a). You can withdraw consent at any time |
| To comply with tax, accounting and legal duties | Legal obligation — Art. 6(1)(c) |
| To train our AI systems and improve the service | Legitimate interest — Art. 6(1)(f); we anonymise where practical and you can opt out (see §7) |
We use a small number of carefully chosen processors. Each has their own privacy terms; each is bound by a Data Processing Agreement under UK GDPR Art. 28.
We do not sell your data. We do not share it with advertising networks. We do not use it to train third-party AI models without an explicit opt-in from you.
Some of the providers above are based in the United States. Where data must leave the UK/EEA, we rely on the UK’s adequacy decisions, the UK International Data Transfer Agreement, or the EU Standard Contractual Clauses, and we apply additional safeguards (encryption in transit and at rest, minimum-necessary disclosure).
| Type | Retention |
|---|---|
| Invoices, payment and tax records | Up to 7 years where required for accounting, tax, disputes or legal obligations |
| Diagnostic and Sprint working material | Normally 12 months after delivery, unless you request earlier deletion or a dispute/legal duty requires longer |
| Marketing leads (no purchase) | 24 months from last contact, then deleted |
| Web logs | 12 months |
| Call recordings & transcripts | 13 months unless flagged for a complaint, dispute, or legal hold |
| WhatsApp / email conversations | Lifetime of the customer relationship + 12 months |
Under UK GDPR you have the right to:
To use any of these rights, email stephen@swarmaisystems.com. We will respond within one calendar month, and faster where we can.
If you are unhappy with how we handle a request, you can complain to the UK Information Commissioner’s Office: ico.org.uk/make-a-complaint, helpline 0303 123 1113.
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We use HTTPS everywhere, Row-Level Security on our database, encrypted backups, and least-privilege access controls. We do not store card details. We perform regular security reviews and update this page if our practices change materially.
If we change anything material in this policy, we will update the “Effective” date at the top and, where the change affects you directly, we will email you.
SWARM AI Systems Ltd, Paisley, Scotland, UK
Company No. SC884785
Email: stephen@swarmaisystems.com